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there is no requirement that the engine of a car be running or that the thief successfully navigate the car onto a street before the crime is complete. See Hicks v. State, 196 Ga.App. 180(1), 396 S.E.2d 33 (1990) (theft by taking evidence sufficient when appellant was standing beside stolen Jeep with broken steering column which belonged to a dealership located 500 yards away); see also Preston v. State, 183 Ga.App. 20(1), 357 S.E.2d 825 (1987) (conviction for theft by receiving affirmed when appellant unsuccessfully tried to start a car which had been reported as stolen).” 17. THEFT OF SERVICES Jackson v. State, 301 Ga.App. 406, 687 S.E.2d 666 (December 3, 2009). Evidence was sufficient to support defendant’s conviction for theft of services by tampering with water meter and obtaining water services without paying therefor. “‘[T]he surreptitious and unauthorized use of electricity or electrical energy is one of the forms of obtaining ‘services' within the meaning of OCGA § 16-8-5.’ (Citations omitted.) Phillips v. State, 204 Ga.App. 698, 703(3) (420 S.E.2d 316) (1992) (‘appellant, without lawful permission, was taking and using electricity in the apartment to heat the stove burners to dry his clothing’) (Id. at 702(3)). For purposes of OCGA § 16-8-5, we see no reason to distinguish between the theft of water services and the theft of electrical services.” Carter v. State, 237 Ga.App. 703, 516 S.E.2d 556 (April 21, 1999). Evidence supported defendant’s conviction for theft of services where he obtained the services of appointed criminal defense counsel by giving false information on an application for a court-appointed lawyer. “Defendant argues the evidence is insufficient to support his conviction on this charge because his appointed attorney sometimes takes ‘criminal cases for nothing at all.’ This testimony certainly does not demand a finding that appointed counsel would have agreed to take this case pro bono. Defendant previously retained this lawyer for his divorce, and counsel charges an hourly fee of $150 for civil work. In our view, evidence that defendant allowed an application for appointed counsel to be submitted in his name, knowing that the application contained deceptively misleading and false information about the true state of his finances, and thereafter obtained and accepted the services of appointed counsel is sufficient … to authorize the jury’s verdict that defendant is guilty, beyond a reasonable doubt, of violating OCGA § 16-8-5 as alleged in the indictment.” 18. THEFT OF TRADE SECRETS DuCom v. State, 288 Ga.App. 555, 654 S.E.2d 670 (November 26, 2007). Evidence supported defendant’s conviction for theft of trade secrets. “Under Georgia law, the crime of theft of a trade secret is defined in relevant part as follows: ‘Any person who, with the intent to deprive or withhold from the owner thereof the exclusive use of a trade secret, or with an intent to appropriate a trade secret to his or her own use or to the use of another, does any of the following: ... (3) Without authority, makes or causes to be made a copy of an article representing such trade secret[.]’ OCGA § 16-8-13(b). A trade secret is defined, in relevant part, to include a list of actual or potential customers or suppliers which is not commonly known by or available to the public and which information: ‘(A) Derives economic value, actual or potential, from not being generally known to, and not being readily ascertainable by proper means by, other persons who can obtain economic value from its disclosure or use; and (B) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.’ OCGA § 16-8-13(a).” Trade secret here was property management company’s master client list; defendant was an employee of the company who took the list to start her own company. 19. VALUE See EVIDENCE – VALUE, above EE. UNIFORM RULES OF THE ROAD (TITLE 40, CHAPTER 6) 1. AGGRESSIVE DRIVING Simmons v. State, 321 Ga.App. 743, 743 S.E.2d 434 (May 13, 2013). Evidence was sufficient to support conviction for aggressive driving where defendant “struck Faircloth's truck four times in rapid succession, and then struck it again as he fled the scene.” Winn v. State, 291 Ga.App. 16, 660 S.E.2d 883 (April 10, 2008). Successive prosecutions for reckless conduct (in state court) and aggressive driving (in superior court), based on same conduct, were not barred by double jeopardy where DA was not aware of prior prosecution in state court. “[E]ach crime requires proof of a fact which the other does not, and so neither offense was included in the other so as to prohibit Winn’s conviction of more than one crime arising out of the same conduct,” citing Drinkard v. Walker, 281 Ga. 211, 212 (636 S.E.2d 530) (2006). In re: A.M.A., 266 Ga.App. 273, 596 S.E.2d 756 (March 15, 2004). Facts were sufficient to support juvenile’s delinquency adjudication based on aggressive driving: “the evidence shows that A.M.A. knew that [victim] was in the car behind her. The evidence also shows that the passengers in A.M.A.’s car yelled obscenities at [victim] and made obscene